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Part Payment of Debt, Common Law by a third party OK: Welby v Drake, Common Law at Creditor's request In Pinnel's case: (i) before due; (ii) at different place; (iii) less worth goods, ie. rule in Pinnel's case: No consideration qulification Equity, factual benefit OK: Williams v Roffey Bros issue Foakes v Beer superseded?, Common Law composition agreement each receive a %, factual benefit OK: Williams v Roffey Bros refused by Re Selectmove, ie. rule in Pinnel's case: No consideration qulification Common Law, In Pinnel's case: (i) before due; (ii) at different place; (iii) less worth goods cash to cheque OK before; but D&C Builders v Rees, ie. rule in Pinnel's case: No consideration distinguish factual benefit OK: Williams v Roffey Bros, Part Payment of Debt general Comm Law ie. rule in Pinnel's case: No consideration